Corrective Action Plans

Finding 15987 (2022-040)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 23129

Finding 15985 (2022-038)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Stat...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has two programs that administer the two different program funding activities. Corrective actions are listed separately for each program to reflect slightly different implementation timelines. Low-Income Home Energy Assistance Program (LIHEAP) The program added all current awards to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System and data entry for the sub-awardees was completed as of April 15, 2022. In April 2022, the program implemented the following procedures to strengthen internal controls and to ensure compliance with the reporting requirements: ? Designated the LIHEAP program manager to be responsible for performing the FFATA reporting duties. ? Established a procedure to monitor subawards upon receiving an award letter from the federal grantor, including reviewing incoming amendments and determining if the threshold for FFATA reporting has been reached. ? Stipulated the due date of report submission to be 30 days after the assistant director signs the obligation memo to ensure that the program meets FFATA reporting deadlines. ? Required each award and amendment to be entered separately into the FFATA Subaward Reporting System. The program provided and will continue to provide training to program staff before the annual technical assistance and training conference for sub- grantees. The training consists of the FFATA requirement overview and walkthrough of the Department?s internal FFATA reporting procedures. The program will continue to review the FFATA procedures on an annual basis to ensure compliance with current federal requirements. Corrective action was completed for the Low-Income Home Energy Assistance Program in April 2022. Low-Income Weatherization Program The Low-Income Weatherization Program added all current awards to the FFATA Subaward Reporting System and data entry of the awards was completed as of January 15, 2023. In response to the finding, the program implemented the following procedures to strengthen internal controls and to ensure compliance with the reporting requirements: ? Award letters and funding allocations will be reviewed by the budget team and assistant director before issuing subawards to the weatherization network. ? Added FFATA reporting requirements to the obligation process for contracting funds, which includes an obligation memo that outlines the amounts the program intends to pass through to subrecipients and contractors. ? Designated the Weatherization Program coordinator to be responsible for performing the FFATA reporting duties. ? Established a procedure to monitor subawards upon receiving an award letter from the federal grantor, including reviewing incoming amendments and determining if the threshold for FFATA reporting has been reached. ? Stipulated the due date of report submission to be 30 days after the assistant director signs the obligation memo to ensure that the program meets FFATA reporting deadlines. The program will provide training to all relevant current staff and future staff at the time of onboarding, including supervisors, program managers, and program coordinators. The training will consist of a FFATA requirement overview and walkthrough of the Department?s internal FFATA reporting procedures. The Department will review the FFATA procedures on an annual basis to ensure compliance with current federal requirements. Corrective action was completed for the Low-Income Weatherization Program in January 2023. The conditions noted in this finding were previously reported in finding 2021-031. Completion Date: January 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 23129

Finding 15981 (2022-037)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistanc...

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistance for Needy Families program. Questioned Costs: Assistance Listing # 93.558 Amount $0 Status: Corrective action not taken Corrective Action: The Department does not concur with the finding. The Department has established processes in place to ensure income information is properly considered during client eligibility and benefits determination for the Temporary Assistance for Needy Families (TANF) Program. During eligibility determination at application intake, the eligibility worker: ? Interviews the client to determine income. ? Compares client reported information and cross matches against the Income Eligibility and Verification System (IEVS) per the Code of Federal Regulations (CFR). ? Resolves discrepancies for all new or previously unverified information received. ? Uses the information to determine if the client income is below the maximum earned income limits for TANF per WAC 388-478-0035. ? Verifies all circumstances as required in WAC 388-490-0005 and follows requirements when discrepancies exist, which include taking appropriate actions if the information is questionable, confusing, or outdated. The Department utilizes Spider, which is a tool that combines several different data matches including IEVS. In addition, the Department uses templates to appropriately and comprehensively document the eligibility determination to ensure consistency, accuracy, and that lean processes are followed. ? The Earned Income Template o Addresses income received within 30 days of the application date and any discrepancies found between the case record, online verification systems, previously projected income, and income type. o Does not require documentation if there is no income reported and when no discrepancy is found in cross matches. ? The Final Narrative Template o Includes completing check boxes to document types of cross matches reviewed during application intake and a summary of the transactions that occurred. In all seven exceptions identified by the auditors, the client?s situation did not require the eligibility workers to use the Earned Income Templates due to: ? No income reported. ? No income found in IEVS and other cross matches. ? No discrepancies. ? No changes within 30 days. The eligibility workers did create documentation using the Final Narrative Template for all seven cases with notation stating: ?Reviewed the following system(s): Spider.? All these actions were consistent and aligned with the Department?s "Standard Remarks and Narrative Documentation? procedures. Alerts are not generated for all income fluctuations but as appropriate when a review and potential action is required. This is to minimize creating unnecessary alerts which would take staff time away from other required and mission-critical actions. The Department asserts that the system is working as designed, which is evidenced by the fact that the Department accurately determined eligibility in all seven cases identified as exceptions by the auditors. The Department will continue to: ? Review IEVS information at application intake and verify and document any discrepancies between what is reported by the household and what is shown in the cross matches. ? Use templates to ensure documentation supports the eligibility decisions. ? Generate alerts when an applicant is budgeted with zero income, but the IEVS data match shows income. ? Use the final narrative documentation template, that includes check boxes, to notate cross matches reviewed during application intake. Completion Date: Not applicable Agency Contact: Rick Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Finding 15980 (2022-036)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.1 § 200.410 § 200.516

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs:...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs: Assistance Listing # 93.558 93.575 93.575 COVID-19 93.596 Amount $5,689 $5,078 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. In response to the finding, the Department established overpayments and referred them to the Office of Financial Recovery for collection. As part of process and internal control improvements, the Department implemented the Fair Start for Kids Act (FSKA) on October 1, 2021, to simplify rules and expand eligibility. The FSKA: ? Raises the State Median Income threshold, increasing the number of eligible two-parent households. ? Caps copayments at $115 for applicants and $215 for reapplicants, reducing the copay amounts for two-parent households. ? Acts as disincentives for fraud as families are less likely to report the non-custodial parent who is not a household member. The Department continues to review cases for accuracy following these new rules and policies. In September 2022, the Office of Child Care (OCC) released a document to help CCDF lead agencies simplify the format and content of child care assistance applications, which includes guidance on defining, collecting, and verifying eligibility information. The Department continues to follow guidance from OCC to update policies and procedures within the authority under the Revised Code of Washington and Washington Administrative Code. This includes: ? Updating policies and procedures for cases with simplified eligibility such as families experiencing homelessness or families with children receiving protective services. Public Benefit Specialist (PBS) staff received training in the winter of 2022, which included the use of systems data to establish household composition. ? Developing a guide for staff to more effectively use the Employment Security Department (ESD) quarterly reported data for eligibility determinations. The ESD data is directly reported by the employer, secured, and reduces delays in benefits by eliminating the wait for employment verification. It is also simple to use for the PBS staff and the auditors, thereby reducing income calculation errors and removing the need for consumers to provide documentation to support the eligibility determination. This procedural change and training are expected to be completed by the summer of 2023. The conditions noted in this finding were previously reported in findings 2021-035, 2020-039, 2019-032, 2018-030, 2017-026, 2016-023, 2015-026, 2014-026, 2013-017 and 2012-30. Completion Date: Estimated October 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15970 (2022-032)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding: The Department of Health did not have adequate internal controls to ensure it filed accurate and timely reports required by the Federal Funding Accountability and Transparency Act for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.26...

Finding: The Department of Health did not have adequate internal controls to ensure it filed accurate and timely reports required by the Federal Funding Accountability and Transparency Act for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department agrees with the finding. The Department will review internal processes and determine when a review is most effective to ensure accuracy and completeness of the Federal Funding Accountability and Transparency Act reporting submissions. Management has already addressed the obligation dates to ensure the execution date of the award or amendment is reported. Completion Date: Estimated July 2024 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129

Finding 15946 (2022-003)

Significant Deficiency 2022

City of Potosi, Missouri

MO

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FEDERAL SIGNIFICANT DEFICIENCY 2022-3 The City has not adopted written policies and procedures related to federal awards as required by Uniform Guidance. Recommendation: We recommend the City adopt the required written policies and procedures requir...

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FEDERAL SIGNIFICANT DEFICIENCY 2022-3 The City has not adopted written policies and procedures related to federal awards as required by Uniform Guidance. Recommendation: We recommend the City adopt the required written policies and procedures required by Uniform Guidance. City?s Response: The City understands the concern. The City will review and update the City of Potosi?s procurement policy to add the federal guidelines to comply with Uniform Guidance. Planned Completion Date for the Corrective Action Plan: The City plans to have its accounting procedures and controls documented by May 1, 2023.

View Audit 19560

Finding 15895 (2022-001)

Significant Deficiency 2022

Community College District of St. Louis

MO

Special Tests & Provisions Student Financial Aid Reporting

U.S. Department of Education Community College District of St. Louis respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mark Swadener, Vice Chancellor of Finance Community College D...

U.S. Department of Education Community College District of St. Louis respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mark Swadener, Vice Chancellor of Finance Community College District of St. Louis 3221 McKelvey Road Bridgeton, MO 63044 Independent public accounting firm: KPM CPAs, PC, 1445 East Republic Road, Springfield, MO 65804 Audit Period: Year ended June 30, 2022 The finding from the June 30, 2022 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered with the number assigned in the schedule. Finding ? Major Federal Award Program Audit 2022-001 Recommendation: We recommend the College implement procedures in order to strictly comply with the requirements of 34 CFR 682.610 and 685.309 as it relates to reporting required to the NSLDS. We further recommend that the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Corrective Action Taken: The Office of the Registrar at Saint Louis Community College investigated he exception and updated our existing reporting procedures beginning with the Fall 2022 semester. The College believes the new procedures will timely identify and report the required enrollment status changes for the National Student Loan Database System (NSLDS). Anticipated Completion Date: Fall 2022 semester

View Audit 19548

Finding 15892 (2022-001)

Material Weakness 2022

Greenwood Charter School

UT

Material Weakness Reporting Matching / Level of Effort / Earmarking

Finding 2022-001 Finding Summary: Greenwood Charter School is required to submit annual financial statements and the proposed budget to the USDA. These items were not provided to the USDA by June 30, 2022. Responsible Individuals: Tracey Nelsen, Director and Matt Lovell, Business Manager Corrective ...

Finding 2022-001 Finding Summary: Greenwood Charter School is required to submit annual financial statements and the proposed budget to the USDA. These items were not provided to the USDA by June 30, 2022. Responsible Individuals: Tracey Nelsen, Director and Matt Lovell, Business Manager Corrective Action Plan: Management will provide a copy of the audited financial statements and copy of the proposed budget to USDA annually. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management has provided the audited financial statements and a copy of the proposed budget to USDA in December 2022 and will continue to ensure all necessary corrective action plan items are submitted to the USDA each year.

View Audit 19543

Finding 15890 (2022-002)

Significant Deficiency 2022

Bethany College

WV

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Management's response to Finding 2022-002 Significant Deficiency- Student Status Changes Response: Bethany College accepts the finding that we have had an unplanned lapse in our enrollment reporting to NSLDS. This lapse is attributable to Bethany's monthly reporting to the National Student Clearingh...

Management's response to Finding 2022-002 Significant Deficiency- Student Status Changes Response: Bethany College accepts the finding that we have had an unplanned lapse in our enrollment reporting to NSLDS. This lapse is attributable to Bethany's monthly reporting to the National Student Clearinghouse. The National Student Clearinghouse information is submitted through the Student Status Confirmation Report process. The records are then updated with NSLDS. Due to transitions in the positions responsible for the reporting, the monthly uploads were not timely and resulted in sequent errors. Additionally, Bethany has had transitions in other offices that led to some of the identified issues regarding graduation dates and withdrawals. Due to the transitions, Lisa Reilly, Associate Provost of Academic Records and Accreditation, is now a key holder in the system. She had received training from the consortium that Bethany participants in for its database and has been working with National Student Clearinghouse on reports and updating student information. Two additional individuals will be identified and trained to process these reports by June 30, 2023. The institution will prepare a standard guide that will be used in the case of any transitions to prevent this this repeated pattern. The training guide will be completed by June 30, 2023. Reilly is working with National Student Clearinghouse on these corrections and aims to have them completed by March 31, 2023. By December 2023, Bethany will establish an internal audit of the submissions during this period of transition.

View Audit 19527

Finding 15889 (2022-004)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

? Finding 2022-004 ? In October 2022, Management enhanced its maintained supporting documentation to provide evidence of review and approval of FEMA expenditures and financial reporting for future FEMA submissions. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15888 (2022-005)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Reporting Matching / Level of Effort / Earmarking § 200.303

? Finding 2022-005 ? On or before September 30, 2023, Management will enhance its maintained documentation to support its lost revenue calculations by NPSR by payer to support amounts submitted on the HRSA PRF portal during fiscal year 2023. In addition, Management will review all HRSA PRF portal s...

? Finding 2022-005 ? On or before September 30, 2023, Management will enhance its maintained documentation to support its lost revenue calculations by NPSR by payer to support amounts submitted on the HRSA PRF portal during fiscal year 2023. In addition, Management will review all HRSA PRF portal submissions of lost revenues covering its fiscal year 2023 and ensure evidence of review and approval of the submissions are present to evidence the presence of adherence to its internal controls. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15883 (2022-002)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Questioned Costs Reporting Allowable Costs / Cost Principles § 200.303

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?...

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?s time and effort and ensure amounts charged to the grant in fiscal year 2023 are supported by these certified records. o Responsible Party: Peggy Wisher

View Audit 19521 Questioned Costs: $1

Finding 15874 (2022-006)

Significant Deficiency 2022

School District of Marathon City

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.214

Child Nutrition Cluster Procurement and Suspension and Debarment Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls...

Child Nutrition Cluster Procurement and Suspension and Debarment Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend that the District review its Uniform Guidance policies with all staff to ensure procurement requirements are understood and implement controls to ensure compliance. We also recommend the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food Service Director now updated on requirements in district policy (6325) on procurement. Necessary controls have been reviewed for any contractual agreements, including debarment documentation, in the future as we are currently in the second year of a five-year contract. Name(s) of the contact person(s) responsible for corrective action: Richard Parks, District Administrator Planned completion date for corrective action plan: January 1, 2023

View Audit 19352

Finding 15870 (2022-003)

None 2022

Simmons University

MA

Student Financial Aid Eligibility Reporting

Finding 2022-003: Enrollment Reporting Award Information Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 In August 2021, p...

Finding 2022-003: Enrollment Reporting Award Information Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans, Federal Pell Grant Program Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Numbers: 84.268, 84.063 In August 2021, prior to the Workday Student implementation "go live" in September 2021, the University was working with their implementation consultants to help with the initial configuration of enrollment reporting in Workday. Since implementation, they have been continuously making updates to the system and processes to prevent errors from occurring. The Registrar?s office has spent significant time working to understand and refine the way that enrollment status data is captured and processed in the system. The Registrar's Office works collaboratively with partners on campus (Financial Aid and Information Technology) on identifying and resolving issues. After turnover and an extended vacancy in the Assistant Registrar position, the new Assistant Registrar started in July 2022, took over the reporting and has worked diligently to more timely identify and address errors and has noted a decrease in the number of system errors and data kickouts as a result of this work. In addition, in September 2022 the University engaged an NSC Data Specialist with Workday Student expertise to help monitor and ensure that issues are identified promptly and resolved. The Registrar?s office continuously monitors and implements Workday system updates to ensure that our system is up-to-date and staff are informed of challenges that are being identified in the larger Workday community. Finally, the Registrar?s Office continues to work closely with its financial aid counterparts, including their Director of Systems, Reporting, and Compliance, to ensure data is processed and reported within the Federal Guidelines. The last phase of this work is finalizing our review of the process and data related to degree transmission, such work as is expected to be completed no later than May 2023. The Assistant Registrar, James Smith, who can be reached at datarequest@simmons.edu, is responsible for the implementation of this corrective action plan.

View Audit 19033

Finding 15869 (2022-002)

None 2022

Simmons University

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened...

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-002: Borrower data and reconciliation reporting Award Information Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 As mentioned above, the University implemented two brand new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. During the first month of the Fall term there were significant challenges with the communication between these systems, which resulted in our first group of loans being disbursed in the last few days of September 29, 2021. It is a known issue that any loans that disburse at the end of the month are not included in the Federal SAS Reconciliation file and as a result this disbursement resulted in significant errors. Ultimately, the University was not able to finalize this reconciliation for this month. As mentioned above, the Financial Aid Office was restructured to provide even greater oversight over our Federal funds. Under the restructured office, the new Associate Director and Manager of Loans and Pell Grants has documented all processes, including reconciliation. Additionally, we created an automated report that is generated after the SAS is received and loaded into PowerFaids. A notification is sent to both the Associate Director/Loan Manager as well as the Director of Financial Aid Systems, Reporting and Compliance to provide documentation that the report was run. The Loan Manager reports to the Director of Financial Aid Systems, Reporting and Compliance who signs the completed SAS reconciliations. This process was fully put into place, including signature, for the 2022-2023 academic year beginning with the September 2022 Reconciliation. The Director of Financial Aid Systems, Reporting and Compliance, Amanda Galban, who can be reached at amanda.galban@simmons.edu, is responsible for the implementation of this corrective action plan.

View Audit 19033

Finding 15868 (2022-001)

None 2022

Simmons University

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened...

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-001: Returns of Title IV Funds Award Information Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 In implementing PowerFaids we were required to set up our own Selection Sets (set group of criteria) for managing all of the disbursements (positive or negative) for each type of fund. For all of our loan funds, we used criteria that included requiring that the particular term have at least half-time enrollment. We used this selection set to disburse (increase or decrease) both the loan to the Student Account (in Workday) as well as to get on the Books with FSA (through COD). We realized that students who took a Leave of Absence or Withdrew from the University needed their own selection set because they would have been updated to have zero credits in the term they took a leave or withdrew. The two instances where we were late in adjustment, we were in the middle of the staffing situation. Documentation had not been written by the Loan Manager at that time. Once we identified the issue with the selection set for students who were withdrawn or on a leave of absence, we reviewed all students with this condition, corrected refunds as appropriate and ensured this was corrected moving forward. The Director of Financial Aid saw a need to have greater oversight on our Federal Funds. She began a process of restructuring the Office as of February 21, 2022 so that the Loan Manager position no longer had direct reports and their main responsibility is the management of federal and private loan portfolios and the federal Pell grant fund. Processes have been documented and all selection sets and processes are managed by this new Associate Director (Loan Manager) who now reports directly to the newly created Director of Financial Aid Systems, Reporting and Compliance April 21, 2022. We do not foresee further issues with return of funds within the required 45-day timeline. The Assistant Vice President, Enrollment Student Services & Director of Financial Aid, Amy Staffier, who can be reached at amy.staffier@simmons.edu, is responsible for the implementation of this corrective action plan.

View Audit 19033

Finding 15866 (2022-003)

Significant Deficiency 2022

Walhalla Community Hospital Association

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2022-03 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra F...

Finding 2022-03 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra Fraser, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program?s reserve fund is completed with formal documentation noting the review. Anticipate Completion Date: 3/27/2023

View Audit 18909

Finding 15833 (2022-030)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions...

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15816 (2022-027)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425...

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425V COVID-19 Amount $0 Status: Corrective action not taken Corrective Action: The Office does not concur with the finding. The Office performed the maintenance of effort (MOE) calculations in accordance with the guidance provided by the U.S. Department of Education (ED). Based on appropriations and past funding, it was determined that the fiscal year 2022 expenditure level did not meet the MOE requirement. The Office followed the federal guidance and directions from a legislative proviso in the enacted state budget (Chapter 334, Laws of 2021, Sec. 954) and submitted a waiver request for fiscal years 2022 and 2023. The waiver was submitted before ED?s stipulated deadline of December 31, 2021. ED?s website confirmed an MOE waiver request was received from Washington state and the status of the request is currently listed as ?under review.? The Office maintains adequate internal controls and has followed all federal and state requirements with due diligence in requesting the MOE waiver. The approval process rests with the federal grantor, and the waiver has not been disapproved. In addition, the Office has been meeting with ED on a monthly basis and is already consulting with the grantor regarding the pending waiver request. The Office will also continue to work with the Legislature, which is the state-level authority for state appropriations, to monitor any updates to federal requirements. Completion Date: Not applicable Agency Contact: Brian Tinney Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (564) 999-1781 brian.tinney@ofm.wa.gov

View Audit 23129

Finding 15797 (2022-001)

Significant Deficiency 2022

Lake Erie Preparatory School

OH

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Finding Number: 2022-001: ESSER ? Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2022 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new c...

Finding Number: 2022-001: ESSER ? Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2022 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 21372

Finding 15796 (2022-001)

None 2022

Princeville Development Corporation

NC

Matching / Level of Effort / Earmarking

PRINCEVILLE DEVELOPMENT CORPORATION P.O. Box 1567 Dunn, North Carolina 28335 CORRECTIVE ACTION PLAN February 27, 2023 ...

PRINCEVILLE DEVELOPMENT CORPORATION P.O. Box 1567 Dunn, North Carolina 28335 CORRECTIVE ACTION PLAN February 27, 2023 USDA, Rural Development 403 Government Circle, Suite 3 Greenville, North Carolina 27834 Princeville Development Corporation, respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Greensboro, North Carolina 27410 Audit period: Year ended December 31, 2022 The finding from the December 31, 2022 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs: Finding 2022-001: U.S. Department of Agriculture, Rural Development, Rural Rental Housing Loans, Assistance Listing #10.415 Recommendation: We recommend that management obtain a collateral agreement or transfer funds to another federally insured banking institution in an amount sufficient to ensure all funds are federally insured. Action Taken: We will review the financial stability of the banking institutions which hold the Partnerships' funds on an ongoing basis. We do not feel at this time that the funds are truly at risk based on current market conditions and the reviews they continually do on the financial stability of the banking institutions holding these funds. We will transfer the funds at any point they believe the funds are truly at risk. If you have questions regarding this plan, please call Neil McLamb at 910-766-6283. Sincerely yours, Neil McLamb CFO, DTH Management Group, LTD

View Audit 20240

Finding 15784 (2022-007)

Significant Deficiency 2022

Vermont Economic Development Authority

VT

Matching / Level of Effort / Earmarking

Management agrees with the finding and the recommendation. Effective December 1, 2022 all IRP supported loans will require proof of appropriate workers compensation insurance prior to loan closing. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-5470...

Management agrees with the finding and the recommendation. Effective December 1, 2022 all IRP supported loans will require proof of appropriate workers compensation insurance prior to loan closing. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-5470 Anticipated Completion Date: December 1, 2022

View Audit 18897

Finding 15783 (2022-006)

Significant Deficiency 2022

Vermont Economic Development Authority

VT

Matching / Level of Effort / Earmarking

Management agrees with the finding and the recommendation. Effective December 1, 2022, all IRP supported loans without a documented exception will require adequate life insurance prior to loan closing. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-...

Management agrees with the finding and the recommendation. Effective December 1, 2022, all IRP supported loans without a documented exception will require adequate life insurance prior to loan closing. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-5470 Anticipated Completion Date: December 1, 2022

View Audit 18897

Finding 15782 (2022-005)

Significant Deficiency 2022

Vermont Economic Development Authority

VT

Matching / Level of Effort / Earmarking

Management agrees with the finding and the recommendation. Management will implement a new loan review checklist to document a second review for each new loan by an individual other than the employee responsible for setting up the loan. Management will also implement a loan file maintenance checkli...

Management agrees with the finding and the recommendation. Management will implement a new loan review checklist to document a second review for each new loan by an individual other than the employee responsible for setting up the loan. Management will also implement a loan file maintenance checklist for secondary review of each loan system change subsequent to initial setup, to be completed by an individual other than the employee responsible for making the change. Responsible Party: Thad Richardson Chief Financial Officer Phone: (802) 828-5470 Anticipated Completion Date: December 31, 2022

View Audit 18897

Finding 15778 (2022-001)

None 2022

Trinity Health

MI

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management

The College?s Financial Aid office has instituted a reconciliation process that is now completed monthly, with timely and appropriate levels of review of the reconciliations. All previous month?s reconciliations were performed and reviewed, and the monthly reconciliation process is now part of the s...

The College?s Financial Aid office has instituted a reconciliation process that is now completed monthly, with timely and appropriate levels of review of the reconciliations. All previous month?s reconciliations were performed and reviewed, and the monthly reconciliation process is now part of the standard month-end procedures.

View Audit 18892

Corrective Action Plans

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